Compliance and Financial Crime Risk Appetite Statement

Yapily maintains a zero tolerance for compliance and financial crime risk exposure, including all Money Laundering (ML) and Terrorist Financing (TF) Risk.

Yapily ensures that it adopts all regulatory, legal requirements and compliance requirements in a proportionate way that satisfies the requirements of the local regulatory authorities in a pragmatic and risk-based manner. Yapily is obliged to transact its business so as to ensure it minimises the risk of its systems and processes being used for ML or TF purposes.

Yapily has strict and transparent standards and continuously seeks to strengthen its processes to ensure compliance with all applicable laws and regulations. Yapily reserves the right to reject any client, payment, or business that is not consistent with its Risk Appetite.

Sanctions Compliance Statement

Yapily is committed to complying with the sanctions laws and regulations of the United Kingdom, European Union, the United Nations, Republic of Lithuania and the United States (the sanctions lists), as well as the applicable sanctions laws and regulations in the jurisdictions in which Yapily operates. This position is taken in order to manage regulatory, legal, operational and liquidity risks, and takes into account broader financial crime concerns.

Yapily’s internal policies prohibit or restrict dealing, directly or indirectly with parties subject to restrictive measures issued by these jurisdictions. Yapily reserves the right to refuse to engage in business involving parties with links to the sanctions lists, even where permitted by applicable sanctions laws and regulations where these activities fall outside of Yapily’s risk appetite. In some cases, this risk appetite may be stricter than our legal obligations.

PROHIBITED JURISDICTIONS

Yapily provides Account Information Services (AIS) and Payment Initiation Services (PIS) within the United Kingdom and European Union only. Yapily will not provide services to any entity or person located in the following jurisdictions:

Prohibited and Restricted Industries

We have defined a financial crime risk appetite that delineates the boundaries within which Yapily Connect operates. Below, we outline the prohibited and high-risk industries, setting expectations for ourselves, our clients and their clients.

“Prohibited” industries or clients denote those we do not engage with—neither our clients nor their clients can fall within this list. “Restricted” indicates higher-risk sectors where we conduct additional due diligence, involving further inquiries from our compliance team and more engagement to ensure alignment with our standards.

This list is not exhaustive, and additional considerations may apply as per our ongoing risk assessments and compliance protocols.

PROHIBITED INDUSTRIES & ACTIVITIES

RESTRICTED INDUSTRIES